E-Reporting Requirements for Foreign Companies Without a Permanent Establishment in France

Publié le 10/11/2025, modifié le 29/04/2026 Lecture 7 minutes

This section summarises the e-reporting requirements concerning transaction and payment data from foreign companies without a permanent establishment in France.

The electronic invoicing (e-invoicing) provided for in Article 289 bis of the French General Tax Code (CGI) covers all transactions of purchases and sales of goods and/or supplies of services carried out in France between VAT-taxable persons established in France (see the section “E-invoicing – an overview”, in French only).
Therefore, e-invoicing (receiving and issuing e-invoices) does not apply to foreign companies that do not have a permanent establishment in France within the meaning of VAT. 
However, there are e-reporting requirements concerning transaction data and, in some cases, payment data, from foreign companies not established in France that carry out transactions considered to take place in France, for which they are liable for French VAT under the rules of the General Tax Code.
E-reporting involves sending the tax authority certain information (e.g. the amount of a transaction, the amount of VAT charged) relating to commercial transactions not covered by e-invoicing.

 

E-reporting implementation timeline for foreign companies without a permanent establishment in France 

    • 1 September 2026 for large enterprises and intermediate-sized enterprises (ISEs) that sell goods or provide services;
   • 1 September 2027 for micro-enterprises, very small enterprises (VSEs) and small- and medium-sized enterprises (SMEs) that sell goods or provide services;
   • 1 September 2027 for enterprises in their capacity as buyers or customers liable for VAT (reverse charge transactions and intra-Community acquisitions), regardless of company size.       
Micro-enterprises, VSEs and SMEs can opt to meet their e-reporting requirements ahead of schedule, beginning on 1 September 2026.

Notes on the various enterprise categories:

    • Micro-enterprises or VSEs employ fewer than 10 people and have annual turnover or a balance sheet total of less than €2m;
   • SMEs employ fewer than 250 people and have annual turnover not exceeding €50m or a balance sheet total not exceeding €43m;
   • ISEs are companies outside the SME category employing fewer than 5,000 people and having annual turnover not exceeding €1,500m or a balance sheet total not  exceeding €2,000m;       
   • Large enterprises are companies that cannot be classified in any of the above categories. Either they employ more than 5,000 people or they have turnover of                more than €1,500m and a balance sheet total exceeding €2,000m.


Company size is assessed as at 1 January 2025, based on the last financial year ended before this date or, if the company did not carry out business in that year, on the first financial year ended as from this date.
The concept of a company is that of a legal unit, since a legal unit can be identified by its SIREN number.
A company moves up to the next category:
- when the workforce criterion is exceeded;
- in the event that the workforce condition is not met, only if annual turnover and the balance sheet total are above the threshold.
For reporting requirements relating to the turnover threshold, overall turnover (generated in France and abroad) is taken into account.

 

E-reporting includes two components: transaction data and payment data

1. E-reporting of transaction data:

  • International B2B transactions:

The foreign companies subject to e-reporting requirements are set out in Article 290(II) of the General Tax Code. These are in particular companies not established in France that: 
- carry out transactions from France with another taxable person not established in France (sales or services considered to take place in France and subject to VAT);
- make intra-Community acquisitions in France that are non-exempt within the meaning of Article 262 ter(II)(3) of the General Tax Code;
- purchase goods in France or services that are taxable in France from a supplier/service provider that is not established and not registered for VAT in France.
Transactions exempt from VAT, such as exports and intra-Community supplies, are excluded from e-reporting requirements.
The following are also excluded from e-reporting requirements:
- transactions that are exempt from VAT under the provisions of Articles 261 to 261 E of the General Tax Code, and exempt from invoicing. This is the case, for example, with certain banking and insurance transactions, medical and health services, educational services and transactions carried out by non-profit organisations managed without personal gain in mind;
- transactions resulting in a defence or security contract within the meaning of the Public Procurement Code;
- transactions carried out subject to a classification measure within the meaning of Article 413-9 of the Criminal Code or covered by a confidentiality clause provided for on grounds of national security by a contract for works, supplies and services or the supply of equipment referred to in Article L.1113-1, (1) to (4) of the Public Procurement Code;
- imports of goods.
 

N.B:
The taxable seller or service provider not established in France is liable for VAT on the supply of goods or services referred to in Article 259 A of the General Tax Code when the buyer of the goods or services does not have a French VAT identification number. Consequently, the seller/service provider is subject to e-reporting requirements.
However, a foreign company not established in France is not liable for VAT in France if its customer is a French or foreign company established or not established in France and registered for VAT in France. In that case, it is the buyer of the goods being purchased or service(s) being provided in France that is subject to e-reporting requirements (VAT reverse charge transactions).
The data to be e-reported is the same as that which must be sent under e-invoicing requirements (transaction e-reporting: what data to report, in French only), excluding the SIREN number for companies that are not established in France and do not have one (the SIREN number must be provided if it is available; otherwise, the company must provide an intra-Community VAT number or, if it does not have one, a foreign tax identification number).

  • B2C transactions: 

Such transactions include sales and supplies of services in connection with a non-taxable person (e.g. retail with individuals) where a transaction is liable for French VAT under the rules of the General Tax Code.
The e-reporting of transaction data does not apply to transactions with a non-taxable person if the operator not established in France is registered with an EU VAT One Stop Shop.
The data to be e-reported concerns daily aggregated VAT-liable transactions, which the tax authority uses to determine the base amounts exclusive of VAT for each VAT rate and the corresponding VAT amounts (transaction e-reporting: what data to report, in French only).

2. E-reporting of payment data 

The transactions concerned are referred to in Articles 289 bis and 290 of the General Tax Code when they relate to supplies of services or the receipt of advance payments for the delivery of goods, regardless of customer type, whether they are established in France or abroad, or whether they are professionals or non-taxable persons.
The e-reporting of payment data does not apply to the option to pay VAT on debits and to reverse charge transactions reported by the customer.
The data to be e-reported is that related to receipt of payment (list of payment data, in French only): the collection date, the amount collected for each VAT rate and, where applicable, the invoice number for transactions for which VAT becomes chargeable upon receipt of payment (for services, advance payments).
Payment data is reported by the entity that receives the payment (issuer of the invoice).

 

Frequencies and deadlines for reporting data to the tax authority

Unlike with the e-invoicing system, invoice data is not reported in the normal course of business or on a daily basis, but rather at intervals set based on the company’s VAT arrangements.
For more information, go to “Frequencies and deadlines for reporting transaction and payment data” (in French only).

 

Choosing an authorised platform

Foreign companies without a permanent establishment in France that are subject to e-reporting requirements must choose an authorised platform, which will send their data onwards to the tax authority.
This choice must be made before 1 September 2026 or 1 September 2027 (depending on the date on which the company will be subject to e-reporting requirements).
For information about authorised platforms, visit the links below:
E-invoicing: authorised platforms  (in French only)
> View the list of authorised platforms (in French only)

 

Contact details for the Non-Residents Tax Directorate 

Tax helpline for non-residents (Monday to Friday from 9am to 4pm): 
+33 1 72 95 20 31

 

 

 

 

 

 

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